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Compliance SFO

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
The Volkov Law Group

The FCPA Enforcement Run Continues into 2017

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Just when we thought 2016 was over and we could all breathe a sigh of relief, DOJ and the SEC have continued to run with a string of new enforcement actions. To all of those prognosticators, paparazzi, commentators, chicken...more

Thomas Fox - Compliance Evangelist

Whom Should You Suspend During an Internal Investigation?

Whom to suspend during any Foreign Corrupt Practices Act (FCPA) investigation is always a delicate question to answer. Unfortunately there is never an easy answer. As the Volkswagen (VW) emission-testing scandal continues to...more

NAVEX

The Future of U.K. Enforcement of Financial Crimes: Four Clues for 2015

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The legal and compliance landscape is changing quickly—it’s up to organisations that do business in the U.K. to strengthen their compliance programmes to meet these new challenges. In this whitepaper, Andrew Foose, vice...more

The Volkov Law Group

FCPA Predictions for 2015 (Part II of II)

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The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more

The Volkov Law Group

GSK China: Did Case Finish with a Bang or a Whimper?

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In typical Chinese fashion, the prosecution of GSK and several GSK executives ended after a one-day “trial.” GSK paid a $489 million fine; and four criminal sentences were handed out with suspension of jail time and orders of...more

Thomas Fox - Compliance Evangelist

Where to Now St. Peter? – Due Diligence Going Forward in China

Whatever you might think of where his career went, Elton John had some great early stuff. I still rank Tumbleweed Connection right up there as one of my favorite albums of all-time. And while it was packed with some great...more

Pillsbury Winthrop Shaw Pittman LLP

The UK Bribery Act, Three Years On: Can We Relax Yet?

The Bribery Act 2010 has now been in force for three years. Despite the announcements and commentary that it heralded a new and aggressive face toward corporate corruption, there have as yet been no corporate prosecutions...more

Dorsey & Whitney LLP

SFO Prevails In First Contested Overseas Corruption Trial

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The U.K.’s Serious Frauds Office prevailed in its first overseas corruption trial, securing a jury verdict in its favor and against two former Innospec executives. The case stems from a referral by the DOJ following FCPA...more

Morgan Lewis

Deferred Prosecution Agreements to Be Introduced in the UK

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Beginning in February 2014, the agreements may be used as a sentencing tool for corporate bribery, fraud, and other economic crimes. Under the UK Crime and Courts Act 2013, which received royal assent in April,...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review - November 25,2013

FDIC Guidance on Deposit Advance Products - On November 21, the FDIC issued final supervisory guidance to FDIC-supervised financial institutions with respect to the risks imposed by certain deposit advance products. ...more

Akin Gump Strauss Hauer & Feld LLP

New Risks Associated with Simultaneous U.S. FCPA and U.K. Bribery Act investigations

On November 20, 2013, during a panel presentation at the 30th International Conference on the Foreign Corrupt Practices Act (“FCPA”), current and former prosecutors from the United States and the United Kingdom discussed the...more

Thomas Fox - Compliance Evangelist

Where Else? JP Morgan Chase Investigation Into Hiring Practices Expands

One of the most dreaded questions in any Foreign Corrupt Practices Act (FCPA) investigation is: Where Else? By this I mean that if you have a systemic failure of internal controls in one geographic area it may well be that...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 19 with Barry Vitou on Bribery Act Updates

In this Episode 19, I visit with Barry Vitou, one-half of thebriberyact.com duo. Barry advises on recent remarks at the PinsentMasons Regulatory Conference by SFO Director David Green on enforcement of the UK Bribery Act and...more

Thomas Fox - Compliance Evangelist

Reports Just In: Invasions From Mars And The UK Bribery Act

On this day 75 years ago Orson Welles caused a nationwide panic with his broadcast of “War of the Worlds” – a realistic radio dramatization of a Martian invasion of Earth. The show began on Sunday, October 30, at 8 pm....more

Thomas Fox - Compliance Evangelist

How To Build A Culture Of Ethics And Compliance: The Greatest Article Ever – Part I

Donna Boehme and Jim McGrath continually rail against the notion that a ‘rogue employee’ causes the majority of bribery and corruption charges under such laws as the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act. ...more

Dechert LLP

SFO Brings First Bribery Act Charges in the UK - What Does This Mean for Your Company?

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The Serious Fraud Office (“SFO”) brought fraud related charges against three directors and one employee of Sustainable AgroEnergy plc (“SAE”), a subsidiary of Sustainable Growth Group (“SSG”) on 14 August 2013, as part of a...more

Morrison & Foerster LLP

UK Bribery Act Comes To Life?

On August 14, 2013, the Serious Fraud Office (SFO) charged three British nationals with offenses under the UK Bribery Act 2010. This is the first Bribery Act prosecution brought by the SFO. While it is impossible to discern a...more

NAVEX

SFO and DPAs: A Good Idea Begins to Spread

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Last Thursday, the U.K. Serious Fraud Office released a draft Deferred Prosecution Agreement Code of Practices (Code) for comment. The draft Code represents a significant milestone for ethics and compliance in general, and...more

Pillsbury Winthrop Shaw Pittman LLP

UK Bribery Act: Red Light, Green Light or Mixed-Signals?

The UK Government has announced a review of the Bribery Act 2010 and its intent to reduce the cost of compliance for small and medium-sized businesses. The main focus will apparently be on facilitation payments. These are...more

Thomas Fox - Compliance Evangelist

The HP Acquisition of Autonomy – Lessons Learned for Doing Compliance ‘By the Book’

Doing something ‘by the book’ means more than following a process. It means following that process during high stress times. One of the things that I think gets missed when discussing compliance programs is the need for rigor...more

Thomas Fox - Compliance Evangelist

Quadrophenia and Four Compliance Issues

This past weekend I saw the remaining members of The Who perform in their Quadrophenia Tour. While I had seen Roger Daltry perform the rock opera Tommy, I had never seen Pete Townsend in concert. To say I was blown away would...more

Thomas Fox - Compliance Evangelist

How Does Your Organization Treat Whistleblowers?

As almost everyone knows, Lance Armstrong spoke for the first time about his performance enhancing drug (PED) use recently on Oprah. On the first night he admitted for the first time that he used PEDs during his seven wins at...more

Thomas Fox - Compliance Evangelist

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

One of the great plays and movies that I enjoy is ‘Glengarry Glen Ross’. As you might expect with anything that David Mamet pens the dialogue is absolutely spot on, fast paced and non-stop. The action generally revolves...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Brings in Lord Gold – Is it Thinking Big Enough?

In December 2012 the BBC online service reported that Rolls-Royce Motor Cars Limited (Rolls-Royce) was in talks with the UK Serious Fraud Office (SFO) regarding potential allegations of bribery and corruption in Indonesia and...more

Dechert LLP

Imminent Thematic Review by FSA of Asset Managers in the UK

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The Financial Services Authority is shortly to embark on a thematic review of asset managers. Its focus will be on the risks of bribery and corruption, sanctions and money laundering. Twenty two firms have already been...more

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